June 23, 2026
Official Issuance of the Measures for Ethical Review and Services for Artificial Intelligence Scientific and Technological Activities (for Trial Implementation) (Mainland China)
On March 20, 2026, ten departments, including the Ministry of Industry and Information Technology, issued the Notice on Printing and Distributing the Measures for Ethical Review and Services for Artificial Intelligence Scientific and Technological Activities (for Trial Implementation) (hereinafter referred to as “the Measures”), which came into force on the same day. Compared with the draft for comments released in August 2025, the Measures have not undergone major changes overall, but they have strengthened the compliance requirements for the ethical review of artificial intelligence, specifically including the following aspects:
I. Strengthening the mandatory nature of the review
First, in terms of the title, the Measures change the original “Measures for Management and Services” to “Measures for Ethical Review and Services,” thereby highlighting the pre‑review requirement. In addition, compared with the draft for comments, Article 9 of the Measures explicitly requires all entities engaging in artificial intelligence (hereinafter referred to as AI) scientific and technological activities to establish an ethics committee, and entities that do not meet the conditions shall entrust a service center for review. In other words, for entities engaging in AI scientific and technological activities, establishing an ethics committee is no longer optional but a compliance obligation that must be fulfilled. Furthermore, Article 11 of the Measures also requires that a service center shall not conduct both the review and the re‑examination of the same project so as to eliminate conflicts of interest, which also demonstrates the emphasis on ensuring that ethical review is genuinely implemented and enforced. In other words, the formal implementation of the Measures marks the official inclusion of ethical review for AI scientific and technological activities in the compliance obligations checklist of AI enterprises.
II. Establishing seven fundamental ethical principles
Compared with the draft for comments, Article 3 of the Measures deletes the principles of “respecting intellectual property rights” and “strengthening assumption of responsibility,” and adds “protecting privacy and security,” thereby formally establishing the seven fundamental principles of artificial intelligence ethics, namely: (1) enhancing human well‑being; (2) respecting life and rights; (3) upholding fairness and justice; (4) reasonably controlling risks; (5) maintaining openness and transparency; (6) protecting privacy and security; and (7) ensuring controllability and trustworthiness.
III. Forming six review dimensions
Compared with the draft for comments, the key review focuses proposed in the Measures largely correspond one‑to‑one with the fundamental principles, forming six review dimensions, including human well‑being, fairness and justice, controllability and trustworthiness, transparency and interpretability, accountability and traceability, and privacy protection, which cover the entire life cycle of AI. The key review focuses are more explicit and detailed and are operable in practice, and also facilitate enterprises in conducting self‑inspection and testing from these six aspects.
IV. Increasing the severity of sanctions
In the draft for comments, if a violation occurred, penalties were imposed solely on the basis of the Law on Progress of Science and Technology, whereas the Measures specify that, where violations of the provisions of the Measures occur in the course of AI scientific and technological activities or in carrying out work related to ethics in AI science and technology, investigations and handling, as well as corresponding penalties, shall be conducted in accordance with the Cybersecurity Law of the People’s Republic of China, the Data Security Law of the People’s Republic of China, the Personal Information Protection Law of the People’s Republic of China, the Law of the People’s Republic of China on Progress of Science and Technology, and other laws and regulations framework and relevant provisions. This not only clarifies the basis for imposing penalties but, in substance, also increases the severity of sanctions.
V. Compliance recommendations
In summary, it can be seen that the Measures indeed clarify the mandatory requirements for the ethical review of artificial intelligence, increase the compliance obligations of AI enterprises, and reflect both the regulators’ emphasis on the safety of applications of artificial intelligence technology and society’s urgent demand for the safety of artificial intelligence technology. It is recommended that enterprises conduct self‑inspection from the following aspects to ensure the safety of their own products:
- Whether an AI ethics review organization has been established or entrusted;
- Whether systems for ethical review and emergency response have been formulated;
- Whether all AI projects undergo a “review first, then implementation” scheme;
- Whether expert re-examination has been completed for high-risk projects;
- Whether the entire process is traceable, with records retained and logs traceable;
- Whether privacy and data security are fully covered;
- Whether mechanisms for periodic follow-up and risk reporting are in place;
- Whether platform registration and annual reporting have been completed.
I. Strengthening the mandatory nature of the review
First, in terms of the title, the Measures change the original “Measures for Management and Services” to “Measures for Ethical Review and Services,” thereby highlighting the pre‑review requirement. In addition, compared with the draft for comments, Article 9 of the Measures explicitly requires all entities engaging in artificial intelligence (hereinafter referred to as AI) scientific and technological activities to establish an ethics committee, and entities that do not meet the conditions shall entrust a service center for review. In other words, for entities engaging in AI scientific and technological activities, establishing an ethics committee is no longer optional but a compliance obligation that must be fulfilled. Furthermore, Article 11 of the Measures also requires that a service center shall not conduct both the review and the re‑examination of the same project so as to eliminate conflicts of interest, which also demonstrates the emphasis on ensuring that ethical review is genuinely implemented and enforced. In other words, the formal implementation of the Measures marks the official inclusion of ethical review for AI scientific and technological activities in the compliance obligations checklist of AI enterprises.
II. Establishing seven fundamental ethical principles
Compared with the draft for comments, Article 3 of the Measures deletes the principles of “respecting intellectual property rights” and “strengthening assumption of responsibility,” and adds “protecting privacy and security,” thereby formally establishing the seven fundamental principles of artificial intelligence ethics, namely: (1) enhancing human well‑being; (2) respecting life and rights; (3) upholding fairness and justice; (4) reasonably controlling risks; (5) maintaining openness and transparency; (6) protecting privacy and security; and (7) ensuring controllability and trustworthiness.
III. Forming six review dimensions
Compared with the draft for comments, the key review focuses proposed in the Measures largely correspond one‑to‑one with the fundamental principles, forming six review dimensions, including human well‑being, fairness and justice, controllability and trustworthiness, transparency and interpretability, accountability and traceability, and privacy protection, which cover the entire life cycle of AI. The key review focuses are more explicit and detailed and are operable in practice, and also facilitate enterprises in conducting self‑inspection and testing from these six aspects.
IV. Increasing the severity of sanctions
In the draft for comments, if a violation occurred, penalties were imposed solely on the basis of the Law on Progress of Science and Technology, whereas the Measures specify that, where violations of the provisions of the Measures occur in the course of AI scientific and technological activities or in carrying out work related to ethics in AI science and technology, investigations and handling, as well as corresponding penalties, shall be conducted in accordance with the Cybersecurity Law of the People’s Republic of China, the Data Security Law of the People’s Republic of China, the Personal Information Protection Law of the People’s Republic of China, the Law of the People’s Republic of China on Progress of Science and Technology, and other laws and regulations framework and relevant provisions. This not only clarifies the basis for imposing penalties but, in substance, also increases the severity of sanctions.
V. Compliance recommendations
In summary, it can be seen that the Measures indeed clarify the mandatory requirements for the ethical review of artificial intelligence, increase the compliance obligations of AI enterprises, and reflect both the regulators’ emphasis on the safety of applications of artificial intelligence technology and society’s urgent demand for the safety of artificial intelligence technology. It is recommended that enterprises conduct self‑inspection from the following aspects to ensure the safety of their own products:
- Whether an AI ethics review organization has been established or entrusted;
- Whether systems for ethical review and emergency response have been formulated;
- Whether all AI projects undergo a “review first, then implementation” scheme;
- Whether expert re-examination has been completed for high-risk projects;
- Whether the entire process is traceable, with records retained and logs traceable;
- Whether privacy and data security are fully covered;
- Whether mechanisms for periodic follow-up and risk reporting are in place;
- Whether platform registration and annual reporting have been completed.
The contents of all newsletters of Shanghai Lee, Tsai & Partners (Content) available on the webpage belong to and remain with Shanghai Lee, Tsai & Partners. All rights are reserved by Shanghai Lee, Tsai & Partners, and the Content may not be reproduced, downloaded, disseminated, published, or transferred in any form or by any means, except with the prior permission of Shanghai Lee, Tsai & Partners.
The Content is for informational purposes only and is not offered as legal or professional advice on any particular issue or case. The Content may not reflect the most current legal and regulatory developments. Shanghai Lee, Tsai & Partners and the editors do not guarantee the accuracy of the Content and expressly disclaim any and all liability to any person in respect of the consequences of anything done or permitted to be done or omitted to be done wholly or partly in reliance upon the whole or any part of the Content. The contributing authors' opinions do not represent the position of Shanghai Lee, Tsai & Partners. If the reader has any suggestions or questions, please do not hesitate to contact Shanghai Lee, Tsai & Partners.
